“Taylor Post-Shinn Doctrine” – The Third Circuit Narrows Rule 60(b)(6) Habeas Relief and Clarifies ‘Reasonable Time’ Post-Martinez

Introduction

In Paul Gamboa Taylor v. Commissioner of Pennsylvania Department of Corrections, the United States Court of Appeals for the Third Circuit confronted a familiar but unresolved tension in federal habeas practice: when, if ever, may a death-sentenced state prisoner reopen a long-final habeas judgment under Federal Rule of Civil Procedure 60(b)(6) to admit evidence that was not presented in state court? The petitioner, Paul Taylor, sought to re-litigate his long-rejected competency and ineffective-assistance claims by introducing late-obtained “1999 evidence” after the Supreme Court’s intervening decision in Martinez v. Ryan. The District Court denied relief; the Third Circuit partly affirmed, partly vacated, and—importantly—crafted a detailed roadmap that now governs:

How courts must bifurcate mixed Rule 60(b) motions into (i) permissible attacks on the integrity of the federal proceedings and (ii) impermissible successive claims on the merits;
What constitutes filing “within a reasonable time” under Rule 60(c)(1) after a seminal Supreme Court decision; and
Why Shinn v. Ramirez bars federal evidentiary development even when Martinez excuses state procedural default.

The judgment therefore crystallises a new working doctrine—the “Taylor Post-Shinn Doctrine”—that substantially limits the utility of Rule 60(b)(6) to reopen habeas cases for new evidence.

Summary of the Judgment

Proper vehicle. A Rule 60(b) motion may challenge only defects in the federal habeas process; any attempt to reassert the merits of a constitutional claim is a second-or-successive petition requiring circuit-court authorisation.
Timeliness. Taylor’s motion, filed 364 days after Martinez, was within a “reasonable time”—the District Court miscalculated the period and therefore abused its discretion on timeliness.
No extraordinary circumstances. Even if timely, Martinez does not permit reopening because Taylor’s ineffectiveness claim had already been adjudicated on the merits; therefore it was not procedurally defaulted, and Martinez is inapplicable.
Shinn bar. Regardless of Martinez, §2254(e)(2) prohibits federal courts from considering new evidence when the petitioner (or counsel) lacked diligence in state court; negligent post-conviction counsel’s omissions are imputed to the prisoner under Shinn.
Disposition. The panel (Shwartz, Krause, & Ambro, JJ.) (i) affirmed the denial of Rule 60(b)(6) relief as to the evidentiary hearing request; (ii) held the timeliness finding erroneous; (iii) vacated and remanded with instructions to dismiss the portion of the motion that functioned as an unauthorised successive petition.

Detailed Analysis

A. Precedents Cited and their Influence

Antiterrorism and Effective Death Penalty Act (AEDPA), 28 U.S.C. §§2244(b), 2254(e)(2)
Provides the overarching statutory framework. The court strictly enforced §2244’s successive-petition gatekeeping and §2254(e)(2)’s evidentiary bar.
Gonzalez v. Crosby, 545 U.S. 524 (2005)
Distinguished permissible Rule 60(b) “procedural” motions from impermissible “substantive” second petitions—foundation for bifurcating Taylor’s motion.
Martinez v. Ryan, 566 U.S. 1 (2012)
Created a narrow equitable exception allowing federal courts to hear procedurally defaulted trial-counsel IAC claims when post-conviction counsel was ineffective. Taylor tried to stretch this exception to excuse his failure to present evidence, not a failure to raise a claim; the court refused.
Shinn v. Ramirez, 596 U.S. 366 (2022)
Clarified that even when Martinez excuses default, a negligent petitioner must still satisfy §2254(e)(2) before federal evidentiary expansion—key authority foreclosing Taylor’s new-evidence request.
Other reinforcing precedents: Shoop v. Twyford (limits on new evidence), Williams v. Taylor (diligence standard), Davila v. Davis, Holland v. Jackson, Maples v. Thomas (abandonment doctrine), and Circuit precedents such as Bracey, Cox v. Horn.

B. Legal Reasoning of the Panel

1. Jurisdictional Sorting – Successive vs. Procedural Attack

Applying Gonzalez, the panel parsed Taylor’s motion:
- The part requesting reconsideration of the IAC merits = successive petition → must be dismissed.
- The part challenging the prior court’s failure to hold an evidentiary hearing = proper Rule 60(b)(6) pathway.

2. Timeliness under Rule 60(c)(1)

“Reasonable time” is case-specific; the District Court’s one-year-and-one-day calculation was factually wrong (filed on day 364), thereby tainting its discretion.
Capital case + pending state proceedings + absence of prejudice to the Commonwealth = one-year delay deemed reasonable.

3. Extraordinary-Circumstances Requirement

Rule 60(b)(6) demands “extraordinary circumstances.” Although timeliness was satisfied, Martinez did not furnish those circumstances because Taylor’s IAC claim was fully adjudicated (no procedural default).
Even if defaulted, Shinn would independently bar federal expansion of the record because Taylor’s counsel’s negligence is imputed to him.

4. Application of §2254(e)(2) After Shinn

“If a prisoner is at fault for an undeveloped state-court record, §2254(e)(2) blocks new evidence absent two narrow statutory gateways—Taylor fits neither.” (slip op. at 15-17)

No new retroactive constitutional rule invoked (sub-§(A)(i)).
“1999 evidence” could have been discovered with due diligence (sub-§(A)(ii)).
Consequently, even reopening would be futile; the evidence remains inadmissible.

C. Anticipated Impact

Strategic Limitation on Rule 60(b)(6)
Post-judgment Rule 60(b)(6) motions must now survive both Gonzalez screening and Shinn diligence scrutiny; litigants cannot rely on Martinez as a universal solvent.
Timeliness Benchmark
Filing within roughly one year of a pivotal Supreme Court decision—absent prejudice—will ordinarily satisfy Rule 60(c)’s “reasonable time,” providing a practical benchmark for counsel.
Record-Development Doctrine
The decision cements within the Third Circuit that failure to develop evidence in initial state post-conviction proceedings—whether through negligence or strategy—forever triggers §2254(e)(2), unless the narrow statutory exceptions apply.
District-Court Practice
District judges must separate mixed Rule 60 motions and issue partial dismissals for successive claims, a procedural nuance explicitly mandated here.

Complex Concepts Simplified

Rule 60(b)(6): A catchall rule allowing a federal court to reopen a final civil judgment for “any other reason” not covered by Rules 60(b)(1)–(5). In habeas, it is strictly limited to procedural-integrity attacks.
Successive Petition: A second or later federal habeas application attacking the same conviction or sentence. Under AEDPA §2244(b), such petitions require prior authorisation from the court of appeals.
Procedural Default: Loss of a federal claim because the prisoner failed to comply with state procedural rules. Martinez offers a limited excuse for trial-counsel IAC claims.
§2254(e)(2): AEDPA provision that ordinarily bars federal courts from considering new evidence unless the prisoner was diligent in state court and meets one of two tight exceptions (new retroactive rule or previously undiscoverable facts + clear-and-convincing innocence showing).
Abandonment versus Negligence: True attorney abandonment (no meaningful agency relationship) may relieve a client of fault; mere negligent representation does not. Here, Taylor’s counsel was negligent but did not abandon him.

Conclusion

The Third Circuit’s precedential opinion in Taylor synthesises post-Martinez and post-Shinn jurisprudence into a coherent, restrictive doctrine governing Rule 60(b)(6) relief in habeas cases. The court acknowledged the equitable allure of reopening a capital case but emphasised that AEDPA’s statutory commands and the Supreme Court’s latest guidance leave scant room for late evidentiary excursions. Practitioners must therefore:

Segregate procedural-integrity claims from merits claims when invoking Rule 60(b);
File promptly—ideally within one year of the triggering event—to satisfy Rule 60(c)(1); and
Demonstrate genuine diligence in state court or else face the virtually insurmountable hurdles of §2254(e)(2).

By reinforcing finality while preserving a narrow avenue for correcting procedural miscarriages, the “Taylor Post-Shinn Doctrine” will likely govern future habeas litigation strategy and district-court management across the Third Circuit and, by persuasive force, beyond.